sip 101 (2016 tceq trade fair presentation) 101 kristin patton sip project manager, air quality...
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SIP 101
Kristin Patton SIP Project Manager, Air Quality Division
Presented to Environmental Trade Fair and Conference May 3, 2016
Air Quality Division • SIP 101 • KJP • May 3, 2016 • Page 2
Agenda
• What is a SIP? • What are the NAAQS? • What are the types of SIP revisions?
• How are SIP revisions developed?
Air Quality Division • SIP 101 • KJP • May 3, 2016 • Page 4
State Implementation Plan (SIP)
• A plan to reduce pollution to meet federal air quality standards that:
– in most cases, applies to areas not meeting federal air quality standards (nonattainment areas);
– establishes control strategies and target dates for reducing emissions;
– describes how the state will monitor air quality and determine compliance with the standards; and
– includes technical and regulatory processes for demonstrating attainment.
• The SIP is: – developed and submitted by the state; and – federally enforceable
Air Quality Division • SIP 101 • KJP • May 3, 2016 • Page 5
Pretest Question #1
There is only one SIP for each state. True or False?
TRUE
SIP revisions are completed as necessary to update the SIP.
Air Quality Division • SIP 101 • KJP • May 3, 2016 • Page 6
SIP Revisions
• Revised as needed – when new laws or rules are enacted
– when a region fails to attain standards or its attainment status changes
– when new data or techniques become available
• Developed with participation fromstakeholders – meetings, comment periods, and public
hearings
The Texas SIP
• Section I: Introduction • Section II: Regional Classification • Section III: Public Participation/Intergovernmental Coordination • Section IV: Preliminary Review • Section V: Legal Authority • Section VI: Control Strategy • Section VII: Compliance Schedule • Section VIII: Texas Air Pollution Emergency Episode Contingency
Plan • Section IX: Air Quality Surveillance Plan • Section X: Review of New Sources and Modifications • Section XI: Source Surveillance • Section XII: Resources • Section XIII: Intergovernmental Cooperation • Section XIV: TCEQ Adopted Rules and Regulations
Air Quality Division • SIP 101 • KJP • May 3, 2016 • Page 7
Air Quality Division • SIP 101 • KJP • May 3, 2016 • Page 10
National Ambient Air Quality Standards (NAAQS)
• Required by the Federal Clean Air Act (FCAA)
• Set by the United States Environmental Protection Agency (EPA)
• Primary health-based standards and secondary welfare standards set for six criteria air pollutants
Air Quality Division • SIP 101 • KJP • May 3, 2016 • Page 11
NAAQS Criteria Air Pollutants
• Standards set for six criteria air pollutants: – Ground-Level Ozone (O3) – Particulate Matter (PM) – Nitrogen Dioxide (NO2) – Sulfur Dioxide (SO2) – Carbon Monoxide (CO) – Lead (Pb)
Air Quality Division • SIP 101 • KJP • May 3, 2016 • Page 12
Current Primary NAAQS
Pollutant Level Averaging Time
Ozone (O3) * 0.070 ppm (2015) Eight-Hour
0.075 ppm (2008) Eight-Hour
Particulate Matter (PM2.5) 12.0 µg/m3 Annual (Arithmetic Mean)
35 µg/m3 Twenty-Four-Hour
Particulate Matter (PM10) 150 µg/m3 Twenty-Four-Hour
Nitrogen Dioxide (NO2) 53 ppb Annual (Arithmetic Mean)
100 ppb One-Hour
Sulfur Dioxide (SO2) 75 ppb One-Hour
Carbon Monoxide (CO) 9 ppm Eight-Hour
35 ppm One-Hour
Lead (Pb) 0.15 µg/m3 Rolling Three-Month Average
Note: Secondary NAAQS are the same as the primary NAAQS for all pollutants EXCEPT SO2, which has a secondary NAAQS of 0.5 ppm over three hours, and PM2.5, which has a secondary NAAQS of 15.0 µg/m3
annually. More information can be found at EPA’s NAAQS webpage (http://epa.gov/air/criteria.html)
* In 1997 EPA revoked the 1-hour ozone standard (0.12 ppm, not to be exceeded more than once per year) and in 2015 the EPA revoked the 1997 eight-hour ozone standard (0.08 ppm); however, some areas have continued obligations under those standards (“anti-backsliding”).
Air Quality Division • SIP 101 • KJP • May 3, 2016 • Page 13
Pretest Question #2
The Federal Clean Air Act requires the EPA to revise the NAAQS every five years. TRUE or FALSE?
FALSE
The EPA is required to review the NAAQS every five years which may or may not
result in a NAAQS revision.
EPA Revises NAAQS
Infrastructure and Transport SIP Revision
State DesignationRecommendations
EPA Nonattainment Designation
Emissions Inventory, RFP,and Attainment
Demonstration SIP Revisions
Redesignation Request and Maintenance Plan SIP
Revision
Redesignation to Attainment
EPA Action
State Action
Air Quality Division • SIP 101 • KJP • May 3, 2016 • Page 15
Air Quality Division • SIP 101 • KJP • May 3, 2016 • Page 16
Infrastructure and Transport SIP Revision
• Describes how the state meets the requirements of FCAA, §110(a) for a new or revised NAAQS
– Infrastructure = Does Texas have the means and authority to implement the SIP? ambient air quality monitoring and data
systems programs for enforcement of control measures
– Transport = Does Texas significantly contribute to nonattainment or interfere with maintenance in another state?
Air Quality Division • SIP 101 • KJP • May 3, 2016 • Page 17
Pretest Question #3
For a new or revised NAAQS, the Federal Clean Air Act requires Infrastructure and Transport SIP revision submittals from:
a. states with nonattainment areas for that NAAQS
b. all states c. states bordering Canada or Mexico d. states that failed to submit an Infrastructure
and Transport SIP revision for the previous NAAQS
B. All states
Air Quality Division • SIP 101 • KJP • May 3, 2016 • Page 18
Infrastructure and Transport SIP Revision
• Required for all NAAQS
• Statewide plan
• Requirement is not tied to nonattainment area designations
• Due 3 years after the promulgation date of a new or revised NAAQS
Air Quality Division • SIP 101 • KJP • May 3, 2016 • Page 20
Pretest Question #4
A nonattainment area is: a. an area designated by the EPA as not
meeting federal air quality standards b. an area for which the state has failed to
submit a SIP revision c. an area designated by the state as not
meeting federal air quality standards d. a and c
A Nonattainment areas are designated by the EPA
EPA Revises NAAQS
Infrastructure and Transport SIP Revision
EPA Action
State Action
State DesignationRecommendations
EPA Nonattainment Designation
Emissions Inventory, RFP,and Attainment
Demonstration SIP Revisions
Redesignation Request and Maintenance Plan SIP
Revision
Redesignation to Attainment
Air Quality Division • SIP 101 • KJP • May 3, 2016 • Page 21
Air Quality Division • SIP 101 • KJP • May 3, 2016 • Page 22
Designations Process
• EPA sets a new or revised NAAQS
• States submit designation recommendations
– Attainment: the area meets the NAAQS
– Nonattainment: the area does not meet the NAAQS
– Unclassifiable: the area cannot be classified based on available information
• EPA makes final designations
– 120-day notice to states if designations differ from recommendations
Air Quality Division • SIP 101 • KJP • May 3, 2016 • Page 23
Pretest Question #5
Nonattainment area designations are made: a. immediately upon NAAQS revision b. on the effective date of the NAAQS revision c. one year following the NAAQS revision d. two to three years following the NAAQS revision
D. Two to three years State recommendations are due one year
following a NAAQS revision. The EPA is required to finalize designations one year later, although
this may be extended by an additional year.
Air Quality Division • SIP 101 • KJP • May 3, 2016 • Page 24
Pretest Question #6
If an attainment area monitors pollutant levels that exceed the NAAQS after initial designations are final, the area is designated nonattainment by operation of law. True or False?
FALSE
Nonattainment area designations must be made through the formal designations
process.
Air Quality Division • SIP 101 • KJP • May 3, 2016 • Page 25
Texas NAAQS Nonattainment Areas
• Ozone – 2008 Standard – 0.075 ppm
Houston-Galveston-Brazoria Dallas-Fort Worth
• Particulate Matter – El Paso for PM10
• Lead – A portion of Collin County in the Dallas-Fort Worth Area
• Nitrogen Dioxide – All areas attainment
• Sulfur Dioxide – No areas designated
• Carbon Monoxide – All areas attainment
MARGINAL (3 Years)
Emissions Inventory
Emissions Statements
Nonattainment NSR Program &
Emissions Offsets
RACT Fixups
I/M Corrections
Conformity
MODERATE (6 Years)
Basic I/M
RACT & RACM Emissions Controls
Attainment Demonstration
Contingency Measures
RFP - 15% VOC Reductions within
6 years
SERIOUS (9 Years)
Enhanced Monitoring and I/M
Modeled Attainment Demonstration
3% per Year VOC Reductions After 6
Years
RFP Milestone Contingency
Measures
Clean Fuels Program
VMT Demonstration
SEVERE (15-17 Years)
VMT Growth Offset
Major Source Fees for Failure to
Attain (185 Fees)
EXTREME (20 Years)
Clean Fuels and Controls for
Boilers
Traffic Controls During Congestion
Air Quality Division • SIP 101 • KJP • May 3, 2016 • Page 27
EPA Revises NAAQS
Infrastructure and Transport SIP Revision
State DesignationRecommendations
EPA Nonattainment Designation
Emissions Inventory, RFP,and Attainment
Demonstration SIP Revisions
Redesignation Request and Maintenance Plan SIP
Revision
Redesignation to Attainment
EPA Action
State Action
Air Quality Division • SIP 101 • KJP • May 3, 2016 • Page 28
Air Quality Division • SIP 101 • KJP • May 3, 2016 • Page 29
Emissions Inventory
• Identifies: – Types of emissions sources present in an area
Stationary Point Sources Area Sources Non-Road Sources On-Road Sources
– Amount of each pollutant emitted – Types of process and control devices employed at
each plant or source category
• FCAA requires states to submit emissions inventory information for all relevant sources in nonattainment areas
Air Quality Division • SIP 101 • KJP • May 3, 2016 • Page 30
Emissions Inventory SIP Revision
• Required for all nonattainment areas, regardless of classification
• Due two years after the effective date of a nonattainment designation
• Provides current and comprehensive data on emissions contributing to nonattainment
• Establishes a Base Year Inventory for the nonattainment area
Air Quality Division • SIP 101 • KJP • May 3, 2016 • Page 31
Reasonable Further Progress SIP Revision
• Describes how incremental emissions reductions requirements will be met in a nonattainment area
• Demonstrates that emissions will be reduced by specified amounts between the base year and the nonattainment area’s attainment year
• For ozone nonattainment areas: – Moderate or higher areas must submit plans
providing for a 15% reduction in VOC emissions – Serious or higher areas must submit plans providing
for additional 3% annual combined reductions of NOX and VOC averaged over three-year increments until the attainment deadline
Air Quality Division • SIP 101 • KJP • May 3, 2016 • Page 32
Pretest Question #7
A reasonable further progress SIP revision demonstrates: a. how a nonattainment area will improve air quality and
meet the NAAQS by the area’s attainment deadline b. how a nonattainment area will continue to meet the
NAAQS once redesignated to attainment c. that emissions will be reduced by specified amounts
between the base year and the nonattainment area’s attainment year
d. a and c
C Attainment of the NAAQS is addressed in an
Attainment Demonstration SIP revision.
Air Quality Division • SIP 101 • KJP • May 3, 2016 • Page 33
Attainment Demonstration SIP Revision
• Describes in detail the strategies and emissions control measures that show how a nonattainment area will improve air quality and meet the NAAQS by the attainment deadline
• Components of an attainment demonstration include: – Monitoring data – Emissions inventory – Photochemical modeling – Control strategy
Air Quality Division • SIP 101 • KJP • May 3, 2016 • Page 34
Pretest Question #8
A state is required to develop Attainment Demonstration SIP revisions for: a. the entire state b. all nonattainment areas in the state c. all attainment areas in the state d. some nonattainment areas in the state, depending
on classification
D For ozone nonattainment areas, states must submit
Attainment Demonstration SIP revisions for nonattainment areas classified as moderate and above.
Components of an Attainment Demonstration: Monitoring Data
• Monitoring Data is used to: – determine if an area is meeting the standard – analyze trends
• Monitoring Data is also used to: – provide information on
transport, meteorology, and emissions sources
– develop estimates of emissions from nonindustrial, mobile, and biogenic sources.
Air Quality Division • SIP 101 • KJP • May 3, 2016 • Page 35
Air Quality Division • SIP 101 • KJP • May 3, 2016 • Page 36
Components of an Attainment Demonstration: Emissions Inventory
• Provides data for a variety of air quality planning tasks:
– Establishing baseline emission levels
– Calculating emission reduction targets
– Control strategy development (quantifies the inventory used to determine potential control strategies for the SIP revision)
– Emission inputs into air quality simulation models
Components of an Attainment Demonstration: Modeling
• Models are used to predict future pollutant levels for use in demonstrating attainment of standards by mandated attainment dates.
• Models estimate the emissions reductions needed to attain the standard and use meteorology, emissions, and chemistry to simulate pollution events and to test control strategies and real-world results.
Real World Situation Computer Grid Simulation
Air Quality Division • SIP 101 • KJP • May 3, 2016 • Page 37
Air Quality Division • SIP 101 • KJP • May 3, 2016 • Page 38
Components of an Attainment Demonstration: Control Strategy Development
• Analysis is done to determine the type and need for emissions reductions to attain the NAAQS.
• State, local, and federal strategies are considered.
• Rules are adopted and incorporated into the SIP as needed.
• Contingency measures are included in the plan to be implemented if the area fails to attain the standard by the attainment date.
Air Quality Division • SIP 101 • KJP • May 3, 2016 • Page 39
Control Strategy Development: RACT and RACM
• Federally required control measures • Reasonably Available Control Technology
(RACT) – Lowest emissions limitation that a particular source
is capable of meeting by the application of control technology that is reasonably available considering technological and economic feasibility
• Reasonably Available Control Measures (RACM) – Helps advance attainment of the NAAQS – Considers technological and economic feasibility as
well as enforceability and practicality
EPA Revises NAAQS
Infrastructure and Transport SIP Revision
State DesignationRecommendations
EPA Nonattainment Designation
Emissions Inventory, RFP,and Attainment
Demonstration SIP Revisions
Redesignation Request and Maintenance Plan SIP
Revision
Redesignation to Attainment
EPA Action
State Action
Air Quality Division • SIP 101 • KJP • May 3, 2016 • Page 40
Air Quality Division • SIP 101 • KJP • May 3, 2016 • Page 41
Determination of Attainment
• Also known as a Clean Data Determination
• The nonattainment area is meeting the NAAQS based on certified monitoring data
• Initiated by a state request or by the EPA
• Final determination from EPA will suspend planning requirements for so long as the area continues to attain the NAAQS
Air Quality Division • SIP 101 • KJP • May 3, 2016 • Page 42
Pretest Question #9
A nonattainment area is redesignated to attainment when the EPA finalizes a Determination of Attainment for the area. True or False?
FALSE
A determination of attainment (or clean data determination) is not a redesignation and does not change an area’s attainment status. It does
suspend planning requirements but not anti-backsliding requirements.
Air Quality Division • SIP 101 • KJP • May 3, 2016 • Page 43
Anti-Backsliding Requirements
• Anti-Backsliding requirements are intended to ensure that air quality in nonattainment areas does not get worse after a standard is revoked.
• Examples include: New Source Review permitting, contingency measures, Failure to Attain fees.
• Areas still designated nonattainment for a revoked standard remain subject to applicable anti-backsliding requirements.
• Anti-backsliding obligations are removed through redesignation.
Air Quality Division • SIP 101 • KJP • May 3, 2016 • Page 44
Redesignation Requirements
• The EPA may redesignate an area to attainment if all of the following conditions are met: – the NAAQS have been attained (clean data); – the state has met all applicable requirements for the
area under the FCAA, §110 and Part D; – the applicable SIP revision has been fully approved
by the EPA under the FCAA, §110(k); – the improvement in air quality is due to permanent
and enforceable reductions in emissions; and – the EPA has fully approved a maintenance plan for
the area under FCAA, §175A.
Air Quality Division • SIP 101 • KJP • May 3, 2016 • Page 45
Redesignation Request and Maintenance Plan SIP Revision
• The Redesignation Request describes how a nonattainment area meets redesignation requirements and how the area will continue to meet the NAAQS once redesignated to attainment.
• The Maintenance Plan should contain: – attainment inventory; – maintenance demonstration; – verification of continued attainment; – monitoring network; and – contingency plan.
• Two 10-year maintenance plans are required.
Air Quality Division • SIP 101 • KJP • May 3, 2016 • Page 46
Pretest Question #10
The EPA will not redesignate a nonattainment area to attainment for a revoked NAAQS. True or False?
TRUE
The EPA recently established a “redesignation substitute” option for
revoked standards.
Air Quality Division • SIP 101 • KJP • May 3, 2016 • Page 47
Redesignation Substitute for Revoked Standards
• EPA’s Ozone Standard SIP Requirements Rule provides the redesignation substitute to remove anti-backsliding measures for revoked ozone NAAQS – Includes substance of FCAA redesignation criteria
• Redesignation Substitute elements – Monitoring data showing attainment of the revoked
NAAQS
– Showing that attainment was due to permanent and enforceable emissions reductions
– Demonstration that the area can maintain the standard for 10 years after approval
Air Quality Division • SIP 101 • KJP • May 3, 2016 • Page 49
Regional Haze SIP Revision
• Describes how the state will meet visibility progress goals in Class I areas – Guadalupe and Big Bend National Parks in Texas
• Establishes goals and strategies to reduce visibility-impacting pollutants to meet a national visibility goal by 2064 – In Texas, primarily NOX, SO2, and PM
• Comprehensive analysis due to the EPA every 10 years and progress reports due every five years through 2064
Air Quality Division • SIP 101 • KJP • May 3, 2016 • Page 50
Program or Rule Update SIP Revision
• Updates to required programs or rules incorporated into the SIP control strategy
• Requires a SIP revision
• Examples include: – Vehicle Inspection and Maintenance (I/M)
Program – Rules for Stationary Sources
Air Quality Division • SIP 101 • KJP • May 3, 2016 • Page 52
SIP Development
• Initial research phase – Data collected and modeled, control strategies
proposed and tested, and the revision drafted
– Typically requires 1-4 years • TCEQ's formal rulemaking process
– Publication of the proposal, public meetings, hearings, review of public comments, and adoption by TCEQ's commissioners
– Takes about six months – Legally binding and enforceable under state law once
SIP revision adopted by the commission • Submitted to the EPA for review and approval
– Federally enforceable after it has been approved by the EPA
Air Quality Division • SIP 101 • KJP • May 3, 2016 • Page 53
Consequences of Failing to Develop an Approvable SIP
• Failure to submit or implement a SIP or submission of a SIP that is unacceptable to the EPA can result in:
– start of a federal implementation plan (FIP) clock;
– SIP call; or
– EPA sanctions or other penalties on the state.
Sanctions can include cutting off federal highway funds and setting more stringent pollution offsets for certain emitters.
Contact Information
• Kristin Patton – SIP Team, Air Quality Planning Section – (512) 239-4907 – [email protected]
• Contact the SIP Team or join our e-mail list – http://www.tceq.texas.gov/airquality/sip/sipcontact.html
Questions?
Air Quality Division • SIP 101 • KJP • May 3, 2016 • Page 54